Please help settle this debate . . .
I've always been of the opinin that for purposes of the recordkeeping requirements under 103.29 for the cash sales of monetary instruments, the purchasor had to be a human being.
In other words, even if the remitter on the check was Acme, Inc., the recordkeeping requirements covered the individual standing in front of the teller making the purchase.
The FFIEC exam manual even states that "banks are required to verify the identity of persons purchasing monetary instruments . . ." [emphasis mine] (page 95).
Am I wrong?
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Opinions are mine and not necessarily those of my employer